Privacy Statement

Last updated and valid from 25th January 2019

This Privacy Statement applies to the websites and services (collectively, the “Services”) provided by Oversee Travel Ltd. and its affiliates (“FairFly”) to you, unless there is a separately posted privacy statement or description for such Services. This statement also applies to other FairFly Services that display this Privacy Statement.

This Privacy Statement explains generally how we receive personal information about you, and what we do with that personal information once we have it. This Privacy Statement does not apply to information which does not permit identification of an individual. This Privacy Statement applies regardless of the type of device you use to access our Services. You may choose not to provide certain information to us but doing so may restrict your ability to use our Services.

How do you learn information about me?

We learn information about you when you or other businesses interact with us and use our services, including when:

you give it to us directly (e.g., when you choose to contact us, or make a request for information);

we collect it automatically through our products and Services (e.g., through your use of the Services); or

someone else provides us information about you (e.g., when our client or a third party (such as an employer, travel agency, global distribution system, travel supplier, etc.) provides us your information in order for us to perform Services for them.

What do you do with the information you gather?

Generally, we use your information to help us operate our business, and to provide and improve our products and Services for you and our clients with which you have a business or employment relationship. Sometimes we try to understand more about you based on information you’ve given to us (e.g., when we use your IP address, browser navigator language, or other techniques to customize languages for some of our Services). When permitted by law or elected by you, we may also use the information to provide you information on additional or new Services and features offered by FairFly or its strategic partners, or important information regarding FairFly.

If you have provided information to our client or a third party who shares your information with us or instructs us to collect or process your information, their privacy statement may also apply. You may also have access to other sites through the FairFly websites. These sites may have different privacy practices, and you should read any privacy notices provided on those sites.

Whose information may be processed in connection with the Services?

In connection with the Services, we process information about different types of individuals. As discussed further below, the information that we process about an individual may depend on how he or she interacts with the Services. These different types of individuals include:

Travelers and Those Acting on Their Behalf. Individual consumers and business travelers (“Travelers”) who book tickets, make reservations, or use other travel-related products or services offered by FairFly Customers or Travel Suppliers using the Services. Subscribers and Travel Suppliers may collect and send FariFly information about Travelers. Subscribers and Travel Suppliers may have collected such information directly from the Traveler, or from another individual who acts on the Traveler’s behalf. FairFly also may receive information about assistants, or other representatives who book travel-related products or services on behalf of other individuals.

Other individuals who use our Services or contact us, and certain other individuals (such as sales leads).

When do you share my information with others?

When we have asked and received your permission to share it.

When we’re required to provide it to our client or a third party from whom we received your information, or with whom you have a business or employment relationship.

For processing or providing products and Services to FairFly or to you.

When we provide information to our business partners to enhance the products and Services we offer.

We may use and share the information we gather to comply with law (including cooperation with regulators or officials), legal process or legal advice.

We may share your information when permitted by law if we believe it is reasonably necessary to protect the rights, property or safety of you, our other users, FairFly or the public.

If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may transfer your information to a successor or affiliate.

We may share information we gather to third parties that our clients have a relationship with such as travel management companies, and other designated businesses that are affiliated with our client, in order to provide Services.

We may share information we gather to otherwise operate our business, including to provide our services, or travel management services.

How do you store and protect information about me?

We implement physical, administrative and technical security measures designed to protect your personal information. FairFly is not responsible for unauthorized access to such information by hackers or others that obtain access through illegal measures.

The safety and security of your information also depends on you. Any content, including information, that you contribute to be shared, published, or displayed on the Services, or transmitted to other users of the Services, either via the Services or via social networking or other third party sites available through the Services, is visible to other users and can be read, collected, or used by them. We urge you to be careful about giving out information in public areas of the Services. You understand and acknowledge that, even after removal, copies of your content, including information, that you contribute to be shared, published, or displayed on the Services, or transmitted to other users of the Service, may remain viewable in cached and archived pages, or might have been copied or stored by other users.

How do you use cookies and similar website technology?

FairFly uses cookies or other similar tracking technologies to provide you with better Services. We may collect information about your activities on our Services through the use of cookies, clear GIFs or web beacons, local shared objects or Flash cookies, or through other similar identifiers and technologies (“Cookies”). Cookies are pieces of information a website transfers to your computer’s hard disk for record-keeping purposes. We use both session and persistent Cookies. Cookies can either be persistent (i.e., they remain on your computer or device until you delete them) or temporary (i.e., they last only until you close your browser). We use first-party and third-party Cookies. First-party Cookies are used and controlled by us. Third-party Cookies are controlled by third parties, mostly for the purpose of analytics.

Cookies can make the Web more useful by storing information about your preferences for a particular site. The use of Cookies is an industry standard, and many major websites use them to provide useful features for their customers. By using our websites, you consent to our use of Cookies and our processing of information collected through such Cookies, in accordance with this Privacy Statement. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser (consult your browser ‘help’ files or visit www.aboutcookies.org or www.allaboutcookies.org to learn more about Cookies and their management). However, if you refuse to accept Cookies, you may not be able to take full advantage of the functionality of the websites or Services. We currently do not respond to “do not track” browser headers with respect to the Services.

Below is a list of Cookies that may be set by our FairFly owned or licensed websites which display this Privacy Statement, and a description of what each is used for. This list may change over time. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality. By using our Services you consent to the cookies you permit.

Besides Cookies, we may use other technologies, such as web logs, scripts, or other applications that recognize your computer and gather information, such as your internet protocol address and type of browser, the type of operating system you are using, the domain name of your Internet service provider, the web pages you have visited, and the type of mobile device and provider used to utilize the Service. We may use this information to manage our websites and online services, including to provide you appropriate and better service. We and others may collect personal information about your online activities over time and across different Web sites.

What if you change this Privacy Statement?

We may need to change this Statement and our notices. The updates will be posted online. If the changes are material to the way we process your personal information, we will announce the update through FairFly’s websites by including a “NEWLY UPDATED” label with the Privacy Statement link on our websites for 30 days after material changes are made. Your continued use of the Services after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post a last updated date at the top of the page containing the Privacy Statement.

How may I control information about me?

You may access and control the information provided to us in a number of ways.

If you maintain an account with us directly, you may update certain information provided to us by working with your account manager or logging into our online platform and editing that information. To the extent that an employer, travel agency or other entity maintains or manages information on your behalf in an online account with us, you may not be able to update such information yourself but may be able to request that such entity do so for you.

You may accept Cookies or change your Cookies settings by activating the appropriate settings on your browser. Check your browser help to find out how to adjust these settings. Please note that certain features of the Service may not be available once cookies are disabled.

If you have another request regarding your personal information, or if you have any questions or comments about this privacy statement and our privacy practices, please direct such inquiries or requests to FairFly at: privacy@fairfly.com or Oversee Travel Ltd, Miconis 5, Tel Aviv, Israel 677721 Attn: Privacy Officer.

If you are dissatisfied, we ask that you contact us first to see if we can resolve the issue. However, if you are an individual in the European Union or certain other jurisdictions, you may have the right to lodge a complaint with the supervisory authority in the country in which you live, in which you work, or in the place of the alleged infringement of your privacy rights.

EU-Specific Notice

These terms apply to personal information collected by FairFly through the Services if you are an EU resident. Where FairFly collects information directly from you through its Services, such personal information is controlled by Oversee Travel Ltd., which is headquartered in the Israel at Miconis 5, Tel Aviv, Israel 677721.

The legal basis for processing of your data includes the purposes set forth above in this Privacy Statement. In some cases, we may additionally process your information based on your consent.

Your personal information will not be stored for longer than necessary for the purposes for which they were collected, or in accordance with applicable law.

Subject to applicable law, you have (i) the right to access and request personal information controlled by FairFly, (ii) the right to request the transmission of the personal information you have provided to us to you or another company, (iii) the right to object to uses or disclosures of your personal information, (iv) the right to withdraw your consent in relation to our processing of your personal information based on your consent (however, such withdrawal of consent will not affect the lawfulness of processing based on consent before such withdrawal), (v) the right to request deletion of your personal information and (vi) the right to request that we restrict processing of your personal information.

You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance, because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before FairFly is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact FairFly’s Representative and/or Data Protection Officer at the location of your choice, below.

If you are dissatisfied, we ask that you contact us first to see if we can resolve the issue. However, if you are an individual in in Europe or certain other jurisdictions, you may have the right to lodge a complaint with an appropriate supervisory authority.

Your California Privacy Rights

California law permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, California residents should send an e-mail to privacy@fairfly.com or write us at: Oversee Travel Ltd, Miconis 5, Tel Aviv, Israel 677721 Attn: Privacy Office.

International Transfers

We’re a global organization headquartered in Israel, and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your personal information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. By giving us personal information, you expressly consent, or the company from whom we received your personal information consents to the processing of your personal information as described in this document.

With respect to sales leads created by FairFly, and information received from individuals directly contacting us, FairFly is typically a controller of such specific personal information.